Debarred and Suspended Parties Policy

Background

Debarment and suspension are actions taken by the Federal government against organizations or individuals who have committed fraud or a criminal offense in violation of federal law.  The Office of Management and Budget requires that all federally awarded recipients comply with the non-procurement debarment and suspension common rule.  This common rule restricts sub-awards and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal Assistance programs or activities.  Failure to comply with this policy may result in severe penalities for the University, including loss of Federal funding.

What is Debarment and Suspension

Suspension - A disqualification from government contracting and subcontracting for a temporary period of time because a company or individual is suspected of engaging in criminal, fraudulent, or seriously improper conduct.  Suspension is to be used on an interim basis pending debarment proceedings

Debarment - An exclusion from government contracting and subcontracting for a reasonable, specified period of time because an individual or vendor failed to perform or their performance was inadequate.

All individuals and entities suspended or debarred are listed on the U.S. General Services Administration (GSA), Excluded Parties Listing System (EPLS).  The search can be performed at www.sam.gov. 

Procedures for Departments to Follow

To ensure that Wesleyan University is not doing business with vendors who have been suspended or debarred from doing business with the Federal government, a department should check the vendor against the EPLS before creating a purchase order or making a payment.  Instructions on how to check a vendor can be found at the Finance website.  If a department identifies a vendor as being suspended or debarred, they should contact the Accounts Payable department so that the vendor may be flagged in the WFS system.

Procedures for Accounts Payable to Follow

All new vendors or individuals being set up in WFS must fill out a Wesleyan Substitute W-9.  This substitute W-9 includes a certification that the individual or business is not currently suspended or debarred. 

For individuals or vendors that are found to be suspended or debarred, Accounts Payable will flag the vendor as such in WFS.  This flag will highlight the vendor in orange as being suspended or debarred if they are used on a voucher thereby alerting the person entering the voucher that they may not pay this vendor with Federal funds.

Procedures for Grants Accounting to Follow

Semi-annually the Grants Accounting office will run a list of all vendors and employees paid from Federal funds.  This list will be reviewed against the EPLS as a double check to make sure no Federal funds have been paid to excluded parties.  If ever a vendor on this list is found to be suspended or debarred, the Grants Accounting office will initiate a journal to move the purchases off the Federal grant.  The Grants Accounting office will also inform Accounts Payable so that the vendor can be flagged in WFS.  Documentation of this semi-annual check must be maintained by the office.